Frequently Asked Questions
Corporate Scheduling Announcement List
OFCCP’s Corporate Scheduling Announcement List (CSAL) is a courtesy notification that a contractor’s establishment(s) or function(s) will undergo a compliance review. Establishments and functions are chosen for review through an administratively neutral process using the Federal Contractor Selection System (FCSS). DCI has put together a list of frequently asked questions to help federal contractors and subcontractors understand what to expect in a compliance review. If you have questions or need additional help, our team is always available to assist.
General Information
What is OFCCP’s Corporate Scheduling Announcement List?
The Corporate Scheduling Announcement List (CSAL) is a courtesy notification to contractors selected to undergo a compliance evaluation. This does not schedule or initiate the audit. The purpose of the CSAL is to:
- Provide the contractor notice to prepare for the compliance evaluation; and
- Encourage contractors to take advantage of OFCCP compliance assistance offerings.
For establishments/FAAPs on a CSAL, when will the compliance evaluation begin?
The compliance evaluation will begin when the scheduling letter and itemized listing are received by the contractor. Items listed in the scheduling letter are due to OFCCP within 30 days of receiving the letter. Contractors should be prepared to be scheduled at any time after the CSAL has been published. Exacting timing is unknown as it will depend on the workload for the district or regional office, as well as the placement of the review on the scheduling list. The OFCCP moves in the order of the list but that order is unknown.
If OFCCP releases a new CSAL, will unscheduled evaluations from prior CSALs be removed from scheduling?
No, CSALs are exhausted prior to moving on to the newest iteration.
Is it possible for an establishment to undergo a review during the scheduling cycle without appearing on a CSAL?
Yes. The list of establishments/FAAPs is not all-inclusive. For example, an establishment of a contractor not on the CSAL may be selected for evaluation due to a complaint, contract award notice, or as a result of a conciliation agreement or consent decree progress report monitoring.
Is there a regulatory or statutory limit on the number of establishments that can be scheduled per contractor?
No. There is no legal limitation on the number of establishments per contractor that OFCCP can schedule for a compliance review.
However, OFCCP typically sets limits on the number of establishments per contractor and on the types of reviews based on factors that include agency resources, and a desire to conduct systemic reviews on a large and diverse population of contractors.
What can I do if the establishment address is wrong, the facility is closed, or the establishment was scheduled in error?
OFCCP collects contract data from USAspending.gov and establishment-level data from the Employer Information Report (EEO-1) filings. Sometimes, this information is outdated. If an establishment listed on the CSAL has an incorrect address or a different mailing address or has closed, please send your requested corrections to the Scheduling Mailbox at OFCCP-DPO-Scheduling@DOL.gov.
If you believe OFCCP should not have selected a facility listed on the CSAL for review, please send an email to the Scheduling Mailbox explaining your reasoning and provide supporting documentation. OFCCP will respond to these inquiries promptly.
Note, OFCCP does not edit the CSAL. If a contractor receives a response from the Scheduling Mailbox confirming that it is exempt from review, it will still appear in the posted list but it will not be scheduled.
Types of OFCCP Reviews
What are the types of compliance evaluations that could appear on a CSAL?
OFCCP releases separate CSALs for construction and supply & service compliance evaluations (S&S).
While construction CSALs only list one type of review (construction), S&S CSALs will include a column for “review type.” The most common types of compliance evaluations are listed below. While these review types may be different, each are scheduled with the same letter and itemized listing. Less common types of audits would be compliance checks or focused reviews, both of which require a different scheduling letter and itemized listing.
- Establishment
- Functional Affirmative Action Program (FAAP)
- Corporate Management Compliance Evaluation (CMCE)
- University
What is covered in a university review?
A university review covers the same information and documents as an establishment review, however, OFCCP considers the entire university campus located in one city as an establishment, regardless of how many separate AAPs a university maintains. University reviews of one campus do not include the university’s other campuses in another city, its medical school, and/or its affiliated hospital. Further, these reviews do not include university extension programs and services that are located outside of the main campus. If a university has multiple campuses in different cities, OFCCP treats each campus as a separate establishment of the university. Similarly, OFCCP treats medical schools and hospitals, if owned by the university, as separate establishments that are not covered by the review.
What is a Corporate Management Compliance Evaluation?
A Corporate Management Compliance Evaluation (CMCE) is a review of a corporate headquarters with an additional focus on ascertaining whether individuals are encountering artificial barriers to advancement into mid- and senior-level corporate management. The CMCE still contains all the aspects of an establishment review, but OFCCP may also request additional documentation regarding how corporate management positions are filled. Additionally, OFCCP typically will conduct an onsite during a CMCE, regardless of whether there are any statistically significant disparities in personnel activity or compensation. See FCCM Chapter 4 for more information.
Can a corporate headquarters be scheduled for an establishment-based evaluation instead of a CMCE review?
Does OFCCP still conduct compliance checks and focused reviews?
Important Details
My company has multiple establishments/functional units on this scheduling list, how will the compliance reviews be managed by OFCCP?
In recent years, companies with multiple evaluations on a CSAL have had their compliance reviews assigned to a single regional office so that both the agency and the contractor can engage in these reviews in a coordinated manner. These evaluations can be, and often are, scheduled concurrently. Alternately, regional offices sometimes coordinate the compliance reviews after each establishment/functional unit is scheduled. This coordination of compliance reviews typically only applies to a contractor’s selected establishments/functional units on a single CSAL and would not consolidate across separate CSALs.
Why was my organization selected for an OFCCP compliance review?
Contractors often find themselves asking “Why me?” when OFCCP has selected one or more of their company’s establishments or functional units for a compliance evaluation. However, OFCCP is mandated to utilize a “neutral” selection process when determining the agency’s next slate of contractors to review. This selection process leverages multiple government data and information sources, various analytics and sorting methodologies, and often focuses on predetermined areas of interest such as industry or sector, geographic regions, and/or types of employment practices (e.g., entry-level hiring).
Though not required by law, OFCCP publishes the methodology used for each CSAL; find all CSAL methodologies here.
How will OFCCP select a contractor for a compliance evaluation that has a single contract that involves both construction and non-construction (supply and service)?
In instances where a single contract involves both construction and supplies and services, OFCCP may select the contractor for a construction or supply and service compliance evaluation based on the information available at the time OFCCP develops the scheduling list and in accordance with the Federal Acquisition Regulations (FAR) 36.101(c).
OFCCP typically releases distinct CSALs for supply and service and construction. Contractors who perform both construction and supply and service work should leverage the published selection methodology to verify any construction contracts were appropriately identified and subsequently used for compliance review selection.
DCI Consulting is experienced in navigating audits for construction and non-construction contractors; reach out if your company is in this complex situation.
